The District of Columbia Court of Appeals found that the retirement board had no evidence to rebut testimony from medical experts claiming the depression suffered was work related. The Court of Appeals therefore reversed and remanded the case to the Retirement Board in Beckman v District of Columbia Police and Firefighters’ Retirement and Relief Board.
A member of the Secret Service since 1981, Stephen Beckman began showing signs of major depression in 1986, which he claimed was a result of long separations from his family on presidential detail. The depression escalated until 1988, when Beckman revealed to a co-worker he had considered killing his boss and himself.
This revelation resulted in a required fitness-for-duty examination and the attending psychiatrist confirming work-related depression. However, he left the decision on return to work up to the Agency. Beckman was returned to work.
Upon his return, Beckman was assigned to the violent crimes task force, further adding to the depression. Additionally, Beckman had been involved in an extramarital affair with a female agent until 1996. In 1997, the two engaged in a shouting match after Beckman accused the female agent of calling his wife. This incident resulted in Beckman seeking help for his depression for the first time since 1988.
The agency’s psychiatrist found Beckman severely depressed from work experiences and informed the Labor Department that he was disabled and unable to work. However, during the Secret Service disability retirement proceedings, the Board found reason to believe the depression was a result of his affair, and therefore denied the higher disability retirement benefit for work related injuries. The ruling came despite testimony from the agency’s psychiatrist that his depression was a result of work related injuries, with the affair a symptom of the depression.
The appeals court found the board acted improperly in rejecting the expert testimony of the cause of depression. Beckman had met the burden of showing work related disability, with no evidence to the contrary.
In remanding the case, the court said, “a major flaw in the Board’s factual finding on the question of the proximate cause of the psychological disability in this case is that it is not a matter within the ken of the average layperson”. Adding, “determining the root cause of a psychological condition and ruling out other possible causes are questions better elucidated by expert opinion”.
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